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#77282 - 05/01/03 02:39 PM Reg O and Lending Limits
GenerousLife Offline
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Joined: Feb 2002
Posts: 1,466
USA
When analyzing insider loans and lending limits, does anyone look at all the exceptions or do you just lump it all together?

We have a customer with lots of different types of loans that will become an insider and want to be sure we have a clear handle on the dollar amount we can lend him.

Section 84 isn't the most reader friendly document.
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General Discussion
#77283 - 05/01/03 06:06 PM Re: Reg O and Lending Limits
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
I guess you might have to get a little more specific, i.e., what type of insider? Director or Exec. Off.?
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#77284 - 05/01/03 06:09 PM Re: Reg O and Lending Limits
Anonymous
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Of course, existing loans would be grandfathered, except when new credit is considered. But I have the same question, is this insider going to be a director or a Reg O officer ?

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#77285 - 05/01/03 06:14 PM Re: Reg O and Lending Limits
GenerousLife Offline
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Joined: Feb 2002
Posts: 1,466
USA
He will become a principal shareholder. Some of his companies deal in installment contracts on consumer paper with full recourse, which have different consideration.

My question is about him specifically, but a more general question is, when you either look at an insider and all their related interests or when looking at all the insiders and THEIR related interests, do you net out the loans that are secured by U.S. obligations for example (since there are no limits on those types of loans).
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"No problem can withstand the assault of sustained thinking." ~ Voltaire
"Sustained thinking gives me a headache." ~Me

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#77286 - 05/01/03 06:18 PM Re: Reg O and Lending Limits
Pale Rider Offline
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under the Lone Star
Yes, I believe you net out the loans secured by cash or government obligations. It is as if those loans didn't exist since you control access to the near cash collateral.
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#77287 - 05/01/03 06:26 PM Re: Reg O and Lending Limits
GenerousLife Offline
Diamond Poster
Joined: Feb 2002
Posts: 1,466
USA
Does anyone have an Excel template that they use to monitor Reg O Lending Limits that they would be willing to share? If you do, I would send you my email address via PM.

Thanks in advance.
_________________________
"No problem can withstand the assault of sustained thinking." ~ Voltaire
"Sustained thinking gives me a headache." ~Me

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